BIR Ruling No. 396-2022

REPUBLIC OF THE PHILIPPINES

BUREAU OF INTERNAL REVENUE DEPARTMENT OF FINANCE

Certificate of Tax Exemption No: Bo{-LEH-- 3 9 6 - 2 U Z 2

CERTIFICATE OF TAX EXEMPTION

TO ALL WHOM IT MAY CONCERN:

solely for family home or dwelling purposes, located at Brgy. Prinza, Teresa, Rizal, a project duly tax and creditable withholding tax on its income received directly in connection with its economic and low-cost housing project, Ridgepoint Subdivision Phase 2, consisting of 756 house and lot units used June 21, 2022, for a period of 3 years beginning from June 2022, or actual start of commercial registered with the Board of Investments (BOI) under Certificate of Registration No. This certifies that BORLAND DEVELOPMENT CORPORATION, is exempt from income dated

operations/selling, whichever is earlier, but in no case earlier than the date of registration of the project with the BOI pursuant to Executive Order (EO) No. 226, otherwise known as the "Omnibus Investments Code of 1987" and Section 2.57.5 (B)(2) of Revenue Regulations (RR) No. 2-98, as amended.

P3,199,200.001 and below, is VAT-exempt under Section 109(1)(P) of the National Internal Revenue Code (Tax Code) of 1997, as amended. The sale of lot only, regardless of the price, shall be subject to VAT pursuant to RA No. 10963. Moreover, the sale by the Company of house and lot and other residential dwellings valued at

the BOI, if any, including those units used for commercial purposes such as leasing, retail stores, offices. applicable taxes under the Tax Code of 1997, as amended. etc., is not covered by this Certificate of Tax Exemption and shall be subject to the payment of However, the sale of house and lot units in excess of the 756 house and lot units registered with

BIR rules and regulations and the Terms and Conditions stated at the back hereof. The Company is liable, however, for all other applicable taxes not discussed above. The grant of tax exemption herein is subject to the compliance with the provisions of applicable

This Certificate of Tax Exemption is being issued on the basis of the facts and documents as represented and submitted. However, if upon investigation, the BIR ascertains that the facts are different, then this Certificate shall be considered null and void.

Issued this day of SEP 2 3 2022

A

Commissioner of Internal Revenue LILIA CATRIS GUILLERMO 00 1 4 7.7 K-1-JAC

As adjusted using the 2010 Consumer Price Index values pursuant to RR No. 8-2021 dated June i 1, 2021

Page 2 of 2 Borland Development Corporation CTE No. BO1-LEH3 9 6 - 2 0 2 2 Date issued SEP 2 32022

OF THE CERTIFICATE OF TAX EXEMPTION TERMS AND CONDITIONS

1. The exemption from income and creditable withholding taxes covers only income

directly attributable to the revenues generated from the project, Ridgepoint Subdivision Phase 2 consisting of 756 house and lot units used solely for family home

cover revenues from units with selling price exceeding P2,000,000.00. Moreover, the or dwelting purposes, located at Brgy. Prinza, Teresa, Rizal. Such exemption shall not 756 house and lot units per Department of Human Settlements and Urban Development (DHSUD) Provisional'License to Sell No. per house & lot package. shall not be sold for more than

The enterprise shall comply with the following milestones and total investment capital:

Building/House construction Start of Commercial Operations Site preparation and development Total Project Cost Milestone Investment Cost (in PhP) and Schedule March 2021 - September 2022 March 2022 - March 2025 June 2022

3. In the computation of the project's ITH. the'following shall apply:

2 Only income generated from the sale of housing units (Ridgepoint Subdivision commercial purposes such as leasing. retail stores, offices, etc. shall be Phase 2 -- Brgy. Prinza, Teresa, Rizal) with selling price not exceeding PhP2.0M and used solely for family home or dwelling purposes and not for qualified. b. Interest income from in-house financing shall not be considered as revenues generated from the registered activity. 4. The Company's entitlement to ITH for its BOI-registered housing project is subject to the compliance with the provisions of the Specific Terms and Conditions of its BOI Registration. 5 Pursuant to Section 4 of Republic Act (RA) No. 107082, the Company is required to the Tax Code, as amended, using the electronic.system for filing and payment of taxes of the BIR. It shall file with BOI a complete annual tax incentives report of its income- based tax incentives, VAT and duty exemptions; deductions, credits or exclusions from RA No. 10708's Implementing Rules and Regulations and Joint Memorandum Circular No. 1-2016 dated September 1, 2016. file its tax returns and pay its tax liabilities, on or before the deadline as provided under the tax base, as may be provided under EQ 226, within the periods prescribed under

T The Company is required to file on or before the 15th day of the fourth month following the Annual Information Return under oath, stating its gross income and expenses The Company shall be constituted as a withholding agent for the government if it acts the close of its accounting period of a Profit and Loss Statement and Balance Sheet with incurred during the taxable year. as employer and any of its employees received compensation income subject to compensation withholding tax, or if it makes payments to individuals or corporations subject to the withholding taxes as source as required under Chapter XIH and Section 57 of the Tax Code, as amended and implemented by RR No. 2-98, as amended.

Finally, the Company's books of accounts and other pertinent records shall be subject of ascertaining whether it is complying with the conditions under which it has been to periodic examination by revenue enforcement officers of this Bureau for the purpose 235 of the Tax Code, as amended. granted tax exemption or tax incentives and its tax liability, if any, pursuant to Section

An Act Enhancing Transparency in the Management and Accounting of Tax Incentives Administered by Investment Promotion Agencies.